BSA/AML Examiner School - Case Study Oct 2023

LCB 12/15 Transaction Testing Checklist 22.8: Non-Governmental Organizations and Charities

Account Open Date

Name of Organization

1 2

12/21/2007 05/01/2009 03/05/2009 01/13/2009

XXXX XXXX

3 XXXX

4

XXXX

3

4

1

2

Y

Y

Y

Y

Is the account opening documentation consistent with the institution's CIP procedures? Does the account opening documentation adequate to form a reasonable belief regarding the identity of the accountholder?

Y

Y

Y

Y

Y Y Y Y

Y '

Y

Is the actual activity consistent with the nature of the customer's business?

Y

Y

Is the actual activity in the account consistent with the expected transactions regarding the account? If any activity appears to be suspicious, review the decision whether or not to file a SAR, using the "SAR Decision Process" checklist in Chapter 5.

NA NA NA NA

Comments: Account statements for September through November 2015 were reviewed. Activity on the accounts appears normal; no unusual or suspicious activity was identified.

8 5